IN THE UNI TED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLI NA CHARLESTON DIVISION
UNI TED STATES OF AMERICA CR. NO.:
18 u.s.c. § 249(a) (1) V. 18 u.s.c. § 247 (a) (2) 18 u.s.c. § 247 (d) (1) 18 u.s.c. § 247{d) (3) DYLANN STORM ROOF 18 u.s.c. § 924 {c) (1) (A) 18 u.s. c . § 924 (c) (1) (C) 18 u.s.c. § 924 ( j) 18 u.s.c. § 3591 18 u.s.c. § 3592
INDICTMENT
THE GRAND JURY CHARGES:
1. Defendant DYLANN STORM ROOF is a wh ite male who, on June 17, 2015, was twenty-one years old.
2 . In April 2015, Defendant DYLANN STORM ROOF purchased a Glock, model 41, .45 caliber pistol .
3 . In the months before June 17, 2015, Defendant
DYLANN STORM ROOF decided to attack African- Ame ricans because of their race. He further decided to attack
African-American worshipers in an African-American church in order to make his attack more notorious .
4 . Prior to June 17, 2015, Defendant DYLANN STORM
ROOF obtained and used the website lastrhodesian. com. He
1 placed on that website a manuscript and photographs expressing his racist beliefs. In the manuscript, DYLANN
STORM ROOF uses racial slurs to describe African-Americans, expresses his belief that white people are superior to
African-Americans, and decries integration. The photographs on lastrhodesian. com include DYLANN STORM ROOF wearing a jacket with flags of two former apartheid African nations, displaying his Glock .45 caliber pistol, and holding a confederate flag.
5. On the evening of June 17, 2015, Defendant DYLANN
STORM ROOF drove to the Emanuel African Methodist Episcopal
(AME) Church in Charleston, South Carolina, commonly referred to as "Mother Emanuel," to attack African-American parishioners engaged in religious activities. He selected
Emanuel AME Church because it had a predominately African
American membership, and because it was significant to the people of Charleston, of South Carolina, and of the Nation.
6 . By attacking African-American parishioners,
Defendant DYLANN STORM ROOF wanted to increase racial tensions across the Nation, and sought retribution for perceived wrongs he believed African-Americans had committed against white people.
2 7. On the evening of June 17, 2015, African-American parishioners at Emanuel AME Church were participating in a religious worship and Bible study group led by Reverend
Clementa Pinckney (a forty-one-year-old African-American man) and attended by Reverend Sharonda Coleman-Singleton (a forty-five-year-old African-American woman), Cynthia Hurd
(a fifty-four-year-old African-American woman), Susie
Jackson (an eighty-seven-year-old African-American woman) ,
Ethel Lee Lance (a seventy-year-old African-American woman), K .M. (an eleven-year-old African-American girl),
Reverend DePayne Middleton-Doctor (a forty-nine-year-old
African-American woman) , Felicia Sanders (a fifty-eight - year-old African-American woman) , Tywanza Sanders (a twenty-six-year-old African-American man), Reverend Daniel
Simmons, Sr. (a seventy-four-year-old African-American man) , Polly Sheppard (a seventy-year-old African-American woman), and Myra Thompson (a fifty-nine-year-old African
American woman) .
8. On the evening of June 17, 2015, Defendant DYLANN
STORM ROOF entered Emanuel AME Church with his Glock, model
41, .45 caliber pistol and eight magazines loaded with hollow-point bullets, with the intent of killing African-
3 . Americans engaged l.Il the exercise of their religious beliefs.
9. The parishioners welcomed Defendant DYLANN STORM
ROOF into their Bible study group, and ROOF sat next to
Reverend Clementa Pinckney.
10. While the parishioners were engaged in religious
worship and Bible study, Defendant DYLANN STORM ROOF drew
his pistol and opened fire on the par ishioners, ki lling
Reverend Sharonda Coleman-Singleton, Cynthia Hurd, Susie
Jackson, Ethel Lee Lance, Reverend DePayne Middleton-
Doctor, Reverend Clementa Pinckney, Tywanza Sanders,
Reverend Daniel Simmons, Sr., and Myra Thompson; and
attempting to kill K.M., Felicia Sanders, and Polly
Sheppard.
COUNTS 1-9 (Hate Crime Act Resulting in Death)
THE GRAND JURY FURTHER CHARGES :
11. The allegations set forth in paragraphs 1 through
10 are repeated and realleged as if set forth fully herein.
12. On or about June 17, 2015, in the District of
South Carolina, Defendant DYLANN STORM ROOF willfully caused bodily injury to the below-listed victims because of their actual and perceived race and color:
4 COUNT VICTIM
1 Reverend Sharonda Coleman- Singleton
2 Cynthia Hurd
3 Susie Jackson
4 Ethel Lee Lance
5 Reverend De Payne Middleton-Doctor
6 Reverend Clemen ta Pinckney
7 Tywanza Sanders
8 Reverend Daniel Simmons, Sr.
9 Myra Thompson
The offenses resulted in the death of each of the victims in Counts 1 to 9.
All in violation of Title 18, United States Code,
Section 249 (a) (1).
COUNTS 10-12 (Hate Crime Act Involving An Attempt to Kill)
THE GRAND JURY FURTHER CHARGES:
13. The allegations set forth in paragraphs 1 through
10 are repeated and realleged as if set forth fully herein.
14. On or about June 17, 2015 , in the District of
South Carolina, Defendant DYLANN STORM ROOF, through the
5 use of a firearm (a Glock, mode l 41, . 45 caliber pistol) ,
attempted to cause bodily injury to the below-listed
victims because of their actual and perceived race and
color:
COUNT VICTIM
10 K.M.
11 Felicia Sanders
12 Polly Sheppard
The offenses included an attempt to kill each of the victims in counts 10 to 12 .
All in violation of Title 18, United States Code,
Section 249(a) (1).
COUNTS 13-21 (Obstruction of Exercise o f Religion Res ulting in Death)
THE GRAND JURY FURTHER CHARGES:
15. The allegations set forth in paragraphs 1 through
10 are repeated and realleged as if set forth fully herein.
16. On or about June 17, 2015, in the District of
South Carolina, Defendant DYLANN STORM ROOF intentionally obstructed by force each victim listed below in the
6 enjoyment of that victim's free exercise of religious beliefs:
COUNT VICTIM
13 Reverend Sharonda Coleman-Singleton
14 Cynthia Hurd
15 Susie Jackson
16 Ethel Lee Lance
17 Reverend De Payne Middleton-Doctor
18 Reverend Clementa Pinckney
19 Tywanza Sanders
20 Reverend Daniel Simmons, Sr.
21 Myra Thompson
The acts of Defendant DYLANN STORM ROOF resulted in the death of each victim listed in Counts 13 to 21 and were in and affected interstate commerce.
All in violation of Title 18, United States Code,
Sections 247(a) (2) and 247 (d) (1).
7 COUNTS 22-24 (Obstruction of Exercise of Religion Involving An Attempt to Kill and Use of a Dangerous Weapon)
THE GRAND JURY FURTHER CHARGES:
1 7. The allegations set forth in paragraphs 1 through
10 are repeated and realleged as if set forth fully herein.
18. On or about June 17, 2015, in the District of
South Carolina, Defendant DYLANN STORM ROOF intentionally obstructed by force and threat of force each victim listed below in the enjoyment of that victim's free exercise of religious beliefs, and attempted to do so:
COUNT VICTIM
22 K.M.
23 Felicia Sanders
24 Polly Sheppard
The acts of Defendant DYLANN STORM ROOF included an attempt to kill each of the victims in Counts 22 to 24; involved the use of a dangerous weapon (a Glock, model 41, .45 caliber pistol); and were in and affected interstate commerce.
All in violation of Title 18, United States Code,
Sections 247 (a) (2), 247 (d) (1), and 247 (d) (3) .
8 COUNTS 25-33 (Use o f a Firearm to Conunit Murder During and In Relation to a Crime of Violence)
THE GRAND JURY FURTHER CHARGES:
19. The allegations set forth in paragraphs 1 through
10 are repeated and realleged as if set forth fully herein.
20. On or about June 1 7, 2015, in the District of
South Carolina, Defendant DYLANN STORM ROOF knowingly used
and discharged a firearm (Glock, model 41, .45 caliber
pistol) during and in relation to a crime of violence for
which he may be prosecuted in a court of the United States
- violations of 18 u.s.c. § 249 as charged in Counts 1 to
9, and violations of 18 U.S . C. § 247 as charged in Counts
13 to 21 - and caused the death of each victim listed below
through the use of t he fire arm in such a manner as to constitute murder as defined in 18 u.s.c. § 1111, in that the Defendant, with malice aforethought, did unlawfully kill each victim with the firearm .
COUNT VICTIM
25 Reverend Sharonda Coleman-Singleton
26 Cynthia Hurd
27 Susie Jackson
9 28 Ethel Lee Lance
29 Reverend De Payne Middleton- Doctor
3 ff Reverend Cl ementa Pinckney
31 Tywanza Sanders
32 Reverend Daniel Simmons, Sr.
33 Myra Thompson
All in violation of Title 18, United States Code,
Sections 924 (c) (1) (A), 924 (c) (1) (C), and 924 (j) (1).
NOTICE OF SPECIAL FINDINGS PURSUANT TO TITLE 18 , UNITED STATES CODE, SECTIONS 3 591 AND 3 592
THE GRAND JURY FURTHER FINDS:
21. The allegations set forth in para9raphs 1 through
20 are repeated and reall eged as if set forth fully herein.
22. As to Counts 13-21 and 25-33, the Defendant DYLANN
STORM ROOF:
(a) was 18 years of age or older at the time of
the offense;
(b) intentionally killed Reverend Sharonda
Coleman- Singleton, Cynthia Hurd, Susie Jackson,
Ethel Lee Lance, Reverend DePayne Middleton-
Doctor, Reverend Clementa Pinckney, Tywanza
10 Sanders, Reverend Daniel Simmons, Sr. , and Myra
Thompson (18 U. S.C . § 3591 (a) (2) (A));
(c) intentionally inflicted serious bodily injury
that resulted in the deaths of Reverend Sharonda
Coleman-Singleton, Cynthia Hurd, Susie Jackson,
Ethe 1 Lee Lance, Reverend DePayne Middleton-
Doctor, Reverend Clementa Pinckney, Tywanza
Sanders, Reverend Daniel Simmons , Sr. , and Myra
Thompson {18 u . s. c. § 3 5 91 (a) ( 2) ( B} ) ;
( d) intentionally participated in an act,
contemplating that the life of a person would be
taken and intending that lethal force would be
used in connection with a person, other than one
of the participants in the offense, and Reverend
Sharonda Coleman- Singleton, Cynthia Hurd, Susie
Jackson, Ethel Lee Lance, Reverend De Payne
Middleton-Doctor, Reverend Clementa Pinckney,
Tywanza Sanders, Reverend Daniel Simmons, Sr., and
Myra Thompson died as a direct result of such act
(18 U.S.C . § 359l(a) (2) (C));
(e) intentionally and specifically engaged in an act of violence, knowing that the act created a
11 grave risk of death to a person, other than one of the participants in the offense, such that participation in the act constituted a reckless disregard for human life and Reverend Sharonda
Coleman-Singleton, Cynthia Hurd, Susie Jackson,
Ethel Lee Lance, Reverend DePayne Middleton-
Doctor, Reverend Clementa Pinckney, Tywanza
Sanders, Reverend Daniel Simmons, Sr. , and Myra
Thompson died as a direct result of the act ( 18
U.S.C. § 3591(a) (2) (D));
(f) committed the offenses charged in Counts 13-21 and 25-33 after substantial planning and premeditation to cause the death of a person ( 18
U.S.C. § 3592 (c) (9));
(g) committed the offenses in Counts 15 and 27
(for killing Susie Jackson who was eighty-seven years old) , Counts 16 and 28 (for killing Ethel
Lee Lance, who was seventy years old), and Counts
20 and 32 (for killing Reverend Daniel Simmons,
Sr. , who was seventy-four years old) on victims who were particularly vulnerable due to old age
( 18 u . s . c . § 3 s 9 2 ( c ) ( 11 ) ) ; and
12 (h) in committing the offenses in Counts 13-21 and
25-33, intentionally killed and attempted to kill
more than one person in a single criminal episode
(18 u.s.c. § 3592 (c) (16)).
WILLIAM N. NETTLES (jnr) UNITED STATES ATTORNEY
ATTORNEY GENERAL CIVIL RIGHTS DIVISION
13 UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION
UNITED STATES OF AMERICA §
~s v. s CRIMINAL NO.
~s
DYLANN ROOF ~s
~s
CERTIFICATE OF THE ATTORNEY GENERAL
I, Loretta E. Lynch, hereby certify that in my judgment, prosecution by the United States of Dylann Roof for violating Title 18, United States Code,§ 249(a){l), is in the public interest and is necessary to secure substantial justice and the state lacks jurisdiction to bring a hate crime prosecution. This certification is made pursuant to Title 18, United States Code,§ 249 .
.[ ...< Signed this 1.t' '-·day of~, 2015 .
. oretta F. Lynch Attorney General UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA CHARLESTON DIVISION
UNITED STATES OF AMERICA § § V. § CRIMINAL NO. § DYLANNROOF § §
CERTIFICATE OF THE ATTORNEY GENERAL
I, Loretta E. Lynch, hereby certify that in my judgment, prosecution by the United States ofDylann Roof for violating Title 18, United States Code, § 247(a)(2), is in the public interest and is necessary to secure substantial justice. This certification is made pursuant to Title 18,
United States Code, § 247 (e).
Signed this J.c "'--day of July, 2015.
Loretta E. Lynch Attorney General